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Interagency Guidance on Consumer Deposit Account Discrepancies Issued to CU Boards and CEOs
Thursday, May 19, 2016 6:40 AM

Five federal regulatory agencies on Wednesday issued guidance to address discrepancies that may occur with amounts deposited by a member or customer and the dollar amount credited to that account.

The “Interagency Guidance Regarding Deposit Reconciliation Practices” discusses consumer protection laws applicable to deposits, including the Expedited Funds Availability Act (as implemented by Regulation CC), the Federal Trade Commission Act, and the Dodd-Frank Wall Street Reform and Consumer Protection Act, and that violations could occur if “credit discrepancies” are permitted or are not resolved in a timely manner.

The guidance does not mandate specific practices. However, it does emphasize the need to reconcile variances resulting from encoding errors, poor image capture, and other issues.

The interagency guidance is being issued by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Consumer Financial Protection Bureau.

“Consumers should not be denied timely access to the full amount of their deposits,” said CFPB Director Richard Cordray. “Today’s guidance should make it clear that we expect financial institutions to take steps to handle and resolve deposit discrepancies and avoid consumer harm.”

In a letter to all CEOs and credit union boards, NCUA Chair Rick Metsger encouraged credit unions to review their policies and practices to address discrepancies between amounts presented by members for deposit and the actual amount credited to the member’s account. "We expect credit unions to design and manage their deposit reconciliation practices to comply with Regulation CC and other applicable laws or regulations as part of maintaining robust compliance management systems," Metsger wrote.

Review the interagency guidance.